Rambaran v. Secretary, Dep't of Corr., No. 14-14242 (11th Cir. 2016)
Annotate this CasePetitioner, a Florida prisoner serving a life sentence for second degree murder among other things, was granted federal habeas relief on the ground that appellate counsel had rendered ineffective assistance by failing to anticipate the Florida Supreme Court’s decision on a jury instruction issue and raise it before the Third District Court of Appeal. The court concluded, however, that the district court failed to apply the double deference standard mandated by 28 U.S.C. 2254 and Strickland v. Washington, and the district court should have evaluated the reasonableness of the state habeas court’s denial of petitioner's ineffective assistance claim. Instead, the district court bypassed that test and went straight to the reasonableness of appellate counsel’s actions. The district court’s error in disregarding the requirements of section 2254(d)(1) led it to skip the dispositive question of whether there was any “clearly established Federal law, as determined by the Supreme Court,” holding that appellate counsel provided ineffective assistance by failing to preserve an issue that was percolating in the courts at the time. The court found that no holding of the Supreme Court clearly establishes that in order to perform within the “wide range of reasonable professional assistance,” counsel must accurately predict how the law will turn out or hedge every bet in the hope of a favorable development. Accordingly, the court reversed the district court's grant of habeas relief.
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